We recently received a letter from our MAC informing us of findings on the Comparative Billing Report (CBR) of SNF Short-Stays for PT / PT and NTA services. Our facility triggered greater than the 90th percentile as compared to our state and jurisdiction related to claims with PT/OT Short-Stays (0-20 days LOS). Wondering if we need to complete a self-audit?  Have you seen this? What should be our next steps?


MACs use Comparative Billing Reports (CBRs) as an educational tool for providers to offer insight into billing patterns and utilization of services in comparison to peers. The MAC will typically include links to additional education material and associated Medicare guidelines. Providers are encouraged to use the information to conduct an internal audit to ensure they are in compliance with the Medicare regulations and prevent improper claims submission in order to avoid future possible pre or post-pay medical review. If you receive a telephone call from a member of the Provider Outreach and Education (POE) department to discuss your CBR results and how it related to proper Medicare coverage and billing guidelines, I’d suggest you take advantage of the opportunity to receive the education offered to gain insight into the MAC’s perspective on the outlier billing practices.

Some considerations for the internal audit:

      • Identify diagnosis / clinical category trends
      • Review a sample of patients to determine whether established Functional Assessment Goals (Section GG ADL/Mobility) were met
      • Audit OT/PT claims to determine if patients achieved established therapy goals
      • Review data related return to hospital or ER visits in <30days
      • Identify any COVID outbreaks which may have impacted the rehab course for the time period in question, along with the ALOS for resident COVID related care
      • Determine the number of COVID patients who required transfer to the hospital setting


Need assistance? Contact Proactive for a compliance review of your therapy services and skilled documentation.


Stacy Baker, OTR/L, CHC, RAC-CT
Director of Audit Services

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